United States v. Rangel

585 F.2d 344 (8th Cir. 1978)

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Nature of the Case

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Facts

D, an employee of the EPA, submitted three vouchers requesting reimbursement for lodging costs incurred in conjunction with three business trips. D attached a photocopy of a duplicate, or a customers' copy of a Master Charge sales slip, as documentation for lodging expenses incurred. The photocopies submitted by D were introduced into evidence with the vouchers, as were the corresponding duplicate merchant copies, which had been retained by the hotelkeepers. The photocopies submitted by D showed greater lodging expenses than did the duplicate merchant copies. The invoice number on the merchant copies matched the number of the photocopied customer copies Rangel submitted to the EPA. The total amount Rangel received in excess of his actual lodging was approximately $53.59. D was convicted and appealed. D contends the admission of the travel authorization forms, travel vouchers, and photocopied Master Charge receipts submitted to the E.P.A. violated the best evidence rule.